German-USA Tax Treaty - help....

I have a client who serves as a short-term missionary in the Black Forest Academy Germany.  Before leaving he rolled his 401(k) into his IRA (non-taxable event).  Germany insists he pay German taxes on the value of the rollover.  They do not recognize "rollovers" as non-taxable.  He's faced with over $15K in German taxes.  Does anyone have advice or a contact who can help us?

Thank You.

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